PRIVACY POLICY 個人情報保護方針(ENGLISH)

1 Categories of Personal Information we collect

• 1.1 We collect the following Personal Information directly from you or indirectly through third-parties, if any. Please note that Personal Information that we collect may differ depending on what service you use.

• 1.2 Our services allow you to share certain details about your preferences, needs, or restrictions, such as “Allergy information” or “Health status and disability information”, through various means including text boxes. Please note that any information you voluntarily provide through these means may be classified as sensitive personal information under applicable laws. We do not use such sensitive personal information for marketing or promotional purposes. The provision of such information is optional, and sensitive personal information that you choose to submit is processed based on your consent, which you may withdraw at any time by contacting us using the details provided in Section 10. “Contact information”.

2 Purposes for processing Personal Information

• 2.1 We process your Personal Information for the purposes below.

• 2.2 Where we need to collect your Personal Information to perform a contract with you, or where we are legally required to collect Personal Information, the provision of such Personal Information is mandatory, and we will not be able to provide services to you without this information. In all other cases, provision of any requested Personal Information is optional.
• 2.3 Our websites use cookies or similar technologies to achieve above purposes. More information about our use of cookies or similar technologies can be found in our Cookie Policy.

3 Sharing Personal Information

• 3.1 We share your Personal Information with the following entities.

• 3.2 We may provide your “Information related to personal information” defined in Act on the Protection of Personal Information (“APPI”) to third-parties including data analysis companies and advertising companies for the purposes listed in Section 2.1, and such third-parties may use such information in conjunction with your “Personal data” (defined in APPI) held by such third-parties.
• 3.3 We will jointly use your Personal Information as follows (In this section, “ONHM” means Okura Nikko Hotel Management Co., Ltd.):

A) Joint Use in relation to reservation records

B) Joint Use in relation to One Harmony membership information

C) Joint Use in relation to data registered on website

D) Joint Use in relation to other Personal Information

4 International Transfer

We may transfer your Personal Information across countries/regions for the purposes described in this Privacy Policy.
The above transfers, in particular to countries or regions that do not provide an adequate level of data protection, will be secured through appropriate contractual arrangements, such as standard contractual clauses specified under the Regulation (EU) 2016/679 (General Data Protection Regulation), and/or other measures required under applicable law.

5 Data Retention

We retain Personal Information for as long as it is necessary to achieve our purposes of use. However, we will keep the data for so long as is reasonably necessary if we are required to retain them by law.
In the event that we delete Personal Information after the above period or for any other reason, we irreversibly destroy Personal Information recorded and stored in electronic files, and shreds or incinerate any Personal Information recorded and stored by paper-based means.

6 Security

We implement necessary and appropriate security measures (including the following measures) to prevent incidents such as leakage, loss, or damage of Personal Information and to protect Personal Information. However, we cannot guarantee that incidents will not occur.

• Administrative measures: Formulating information security policies and conducting regular training for employees
• Technical measures: Implementing access controls for systems storing Personal Information, encrypting information, and deploying security software
• Physical measures: Restricting access to rooms and facilities storing Personal Information and key control

7 Children Data

Our services do not knowingly collect Personal Information from children who do not have the ability to independently consent to the processing of Personal Information under applicable laws. If you are a parent or guardian and are concerned that your child has provided us with Personal Information without your consent, you should contact us as indicated in Section 10 “Contact Information”.

8 Privacy Rights

• 8.1 You have certain rights with respect to Personal Information depending on the applicable law. These may include the following rights:
  - Ask us for a copy of your Personal Information;
  - Correct, delete or restrict our processing of your Personal Information;
  - Obtain some Personal Information you provide to us in a structured, machine-readable format;
  - Object to our processing your Personal Information (or those of a third-party), including processing for direct marketing or profiling for purposes of direct marketing; and
  - Where we have asked for your consent, to withdraw consent at any time. If you ask to withdraw your consent, this will not affect any processing which has already taken place at that time.
• 8.2 You can exercise these rights by contacting us as indicated in Section 10 “Contact Information”. These rights may be limited, for example, if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
• 8.3 If you have unresolved concerns, you have the right to complain to a data protection authority in the country/region that you live in, or where the alleged infringement occurred.

9 Changes to this Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to this Privacy Policy and, where required by applicable law, request your consent to such changes.

10 Contact information